Pay transparency in Greece: what employers must do.

Who is covered

The rules on pay structures, on the right to information, on reporting and on the joint pay assessment (Labour Code, arts 37 and 56Α to 56Δ) apply to all employers and to all employees with a contract or relationship of dependent employment in the private sector. They also apply to the public sector, with some differences that this page does not cover (art. 47 par. 2). The rules on recruitment (art. 41) protect applicants for employment (art. 47 par. 3).

Pay has a wide meaning. It is the ordinary basic or minimum wage or salary and any other consideration, in cash or in kind, that the employee receives directly or indirectly from the employer for the work, including complementary or variable components (art. 35 (ε)). Bonuses, allowances and benefits in kind are therefore counted.

Employee representatives, for these rules, are the lawful representatives of the most representative trade union of the undertaking (art. 35 (ιστ)).

The criteria and access to them

The criteria must take into account skills, effort, responsibility and working conditions, and any other factor relevant to the job or position, for example seniority and relevant soft skills. Where employee representatives exist, the criteria are agreed with them (art. 37 par. 3). An employer bound by a collective agreement may use the classifications and pay scales of that agreement (art. 37 par. 2).

The employer makes easily accessible to its employees the criteria used to set pay, pay levels and pay progression. An employer with fewer than 50 employees may leave out the information on pay progression (art. 37 par. 4). The information is given in a format accessible to persons with disabilities (art. 37 par. 5).

Before hiring: pay information and pay history

An applicant has the right to receive from the prospective employer information on the initial pay or its range for the position, based on objective, gender-neutral criteria, and on the relevant provisions of any collective agreement the employer applies to the position (art. 41 par. 3).

The information is given by any suitable means, in writing or orally, in reasonable time before the job interview or, where no interview is held, before the employment contract is concluded. The law gives job advertisements, notices and postings on professional networking sites as examples. The pay or range therefore does not have to appear in the advertisement itself, provided the applicant has it in good time before the interview.

The employer, and any person acting on its behalf, may not ask applicants about their pay history in current or earlier employment, at the interview or in any other contact about the vacancy (art. 41 par. 4). Vacancy notices and job titles must be gender-neutral and the recruitment process must not discriminate (art. 41 par. 2).

The employee's right to pay information

On request, the employer gives the employee in writing the employee's individual pay level and the average pay levels, broken down by sex, for the categories of employees doing the same work or work of equal value (art. 56Α par. 1). The main rules are:

• The request may be made in person, through the employee representatives or through the Ombudsman (Συνήγορος του Πολίτη). If the employer does not reply, or the reply is inaccurate or incomplete, the employee may ask for further reasonable clarification and is entitled to a reasoned answer.
• The employer replies within a reasonable time and in any event within two months of the request.
• Once a year the employer informs all employees of this right and of the steps for exercising it.
• The employer may refuse a request that is manifestly disproportionate or abusive, in particular because it is repetitive. The employee may then ask for the information through the Ombudsman, who decides whether the request is well founded.
• Contracts, collective agreements and work rules may not stop employees from disclosing their own pay in order to uphold equal pay. The employer may require that information received about others be used only to exercise the right to equal pay; employees and their representatives owe confidentiality, and the employer may claim damages if it is breached.
• For temporary agency workers, the user undertaking gives the information after obtaining the individual pay level from the agency.

Gender pay gap reporting: who reports and when

Employers with at least 100 employees report on the gender pay gap in their undertaking. The information concerns the previous calendar year (art. 56Β par. 1 and 4). The number of employees is the average over the previous calendar year. The dates are those of article 9 of the Directive:

• 250 employees or more: by 7 June 2027, and every year after that by the same date.
• 150 to 249 employees: by 7 June 2027, and every three years after that.
• 100 to 149 employees: by 7 June 2031, and every three years after that.
• Fewer than 100 employees: no duty. Such an employer may report voluntarily every three years.

What is reported and to whom

For the first report of employers with 150 employees or more, the reference period runs from the entry into force of the law to 31 December 2026 (Law 5316/2026, art. 30 par. 1). The law does not say expressly whether that means 6 July 2026 (art. 48 par. 1) or 1 November 2026, when the reporting duty applies (art. 48 par. 2); employers should keep data from 6 July 2026. The report contains (art. 56Β par. 1):

• The overall gender pay gap and the median gender pay gap.
• The gender pay gap and the median gender pay gap in complementary or variable components of pay.
• The proportion of female and male employees who receive complementary or variable components.
• The proportion of female and male employees in each quartile pay band.
• The gender pay gap by category of employees, broken down by ordinary basic wage or salary and by complementary or variable components.

Calculation, confirmation and follow-up

The figures are calculated on gross annual pay and the corresponding gross hourly pay of each active employee. Part-time employees are included in the same way, and a user undertaking includes the temporary agency workers who work for it, with data that the agency must supply (art. 56Β par. 2 and 3).

The management of the employer confirms the accuracy of the information in writing, after consulting the employee representatives where they exist, and the representatives have access to the methods used (art. 56Β par. 5). The information is communicated to the Ombudsman, who publishes all of it except the gap by category of employees on an electronic platform that allows comparison between employers, sectors and regions (art. 56Β par. 6; Law 3094/2003, art. 3 par. 7). The details of the platform are to be set by joint ministerial decision (Law 3094/2003, art. 10Α).

The gap by category of employees is given to all employees and to their representatives and, on request, to the Labour Inspectorate and the Ombudsman within two months (art. 56Β par. 8). Employees, their representatives, the Inspectorate and the Ombudsman may ask for further clarification, including an explanation of any gender pay differences, and the employer gives a reasoned answer within two months. Where differences are not justified by objective, gender-neutral criteria, the employer takes corrective measures within six months (art. 56Β par. 9).

An employer that publishes a sustainability report under Law 5164/2024 may include the information in that report and must then tell the Ombudsman in writing where it appears (art. 56Β par. 7).

Joint pay assessment

An employer subject to reporting carries out a joint pay assessment with the employee representatives when three conditions are all met (art. 56Γ par. 1):

• The report shows a difference in average pay level between female and male employees of at least 5% in any category of employees.
• The employer has not justified the difference by objective, gender-neutral criteria.
• The employer has not corrected the difference within six months of submitting the report.

Content and consequences of the assessment

Where there is no trade union, the employees are represented in the assessment by the three employees with the longest service, unless these choose another form of representation (art. 56Γ par. 1).

The assessment sets out the proportion of women and men in each category, their average pay levels and variable components, the differences and the reasons for them, the pay improvements of employees after maternity, paternity, parental or carers' leave, the measures to address unjustified differences, and an evaluation of measures from earlier assessments (art. 56Γ par. 2).

The employer makes the assessment available to employees and their representatives and, on request, to the Labour Inspectorate, and communicates it to the Ombudsman. It applies the resulting measures and corrects unjustified differences within one year of that communication, in cooperation with the employee representatives (art. 56Γ par. 3 and 4).

Personal data

Pay information is given in line with the GDPR and Law 4624/2019, and personal data processed for these purposes may not be used for anything other than applying equal pay (art. 56Δ par. 1 and 2). Where disclosure would reveal, directly or indirectly, the pay of an identifiable employee, only the employee representatives, the Labour Inspectorate or the Ombudsman have access to it (art. 56Δ par. 3).

Burden of proof and evidence

Under the existing rule, once a person puts forward facts from which discrimination may be presumed, the employer must prove that there was no breach of equal treatment (art. 54 par. 1). Law 5316/2026 added the following (art. 54 par. 3 to 6):

• The same reversal applies in a pay discrimination case where the employer has not met its pay transparency duties, in particular those of articles 37, 41 and 56Α to 56Δ. It does not apply if the employer proves that the breach was manifestly unintentional and of minor importance.
• The comparison is not limited to employees of the same employer. It extends to a single source that sets the pay conditions.
• The comparison is not limited to employees who work at the same time as the claimant.
• In court proceedings on an equal pay claim, the court may order the defendant to disclose any relevant evidence under its control, including evidence that contains confidential information.

Compensation, sanctions and limitation

The rules on remedies were tightened (arts 44, 52, 53 and 573):

• Compensation. A breach of equal pay or of the pay transparency duties gives the person affected a claim to full compensation, with no upper limit: actual loss, loss of profit and moral damage. The court takes into account in particular back pay and related bonuses or payments in kind, default interest and the loss of income and of career opportunities (art. 53 par. 1).
• Administrative fines. The breach is also a breach of labour law, for which the Labour Inspectorate imposes the sanctions of article 572 of the Labour Code, including a fine of 300 to 50,000 euros per breach and temporary suspension of operations (art. 53 par. 2; art. 572 par. 1). The method of calculation and the amounts for these breaches are to be set by decision of the Minister of Labour (art. 57Α par. 2).
• Compliance orders. On a complaint, the Labour Inspectorate, working with the Ombudsman, may order the employer to end the breach and to take measures to comply. If the order is not carried out, a fine is imposed again for every three months of delay (art. 573 par. 3Α; art. 576Α).
• Retaliation. Dismissal or any other unfavourable treatment of employees or their representatives is prohibited when it is a reaction to a complaint within the employer's organisation or to administrative or court proceedings on equal pay (art. 44 (δ)).
• Who may act. With the consent of the person affected, the Ombudsman, trade unions and other legal persons with a legitimate interest may bring proceedings in that person's name or intervene in support (art. 52 par. 2).
• Limitation. The limitation period for equal pay claims does not begin before the person affected knows of the breach or could reasonably be expected to know of it. Knowledge is presumed, subject to proof to the contrary, when the employee receives pay information under article 56Α or when the employment ends (art. 53 par. 3). This rule applies only to claims that arise after the entry into force of Law 5316/2026 (Law 5316/2026, art. 30 par. 2).

Pay disputes before the Labour Inspectorate

A private-sector employee may bring a labour dispute before the Labour Inspectorate for alleged pay discrimination on grounds of sex and ask for corrective measures (art. 570Α). For the employer the procedure works as follows:

• The Inspectorate notifies the request to the employer together with a call to provide information on its pay-setting and pay-progression policy, the criteria used and the average pay levels by sex for the category compared. The request is also sent to the Ombudsman, who may attend the hearing.
• If there are indications of pay discrimination, the employer is called on to justify them. Failure to provide the information counts as failure to justify, and pay differences that the employer does not justify are presumed to be discriminatory.
• Where the employer is bound by a collective agreement that sets pay by job specialisation on gender-neutral criteria, it is presumed that there is no unjustified pay discrimination.
• If the inspector finds pay discrimination, the employer is called on to comply and to present corrective measures, to be carried out within six months at the latest. The inspector may also order measures directly.
• Unjustified failure to appear or to comply brings the administrative sanctions of article 572.

Practical steps for the employer

The duties of general application have been in force since 1 November 2026. In practice an employer should:

• Write down its pay structure: the categories of employees, the components of pay for each and the criteria used, and check them against article 37. Where it applies a collective agreement, record which classifications and scales it uses.
• Prepare the initial pay or range for each vacancy and decide how applicants receive it before the interview. Remove questions on pay history from application forms and interview guides, and instruct recruiters and agencies that act for the company.
• Check that vacancy notices and job titles are gender-neutral.
• Review employment contracts, policies and work rules for terms that forbid employees to disclose their own pay.
• Set a procedure for employees' information requests that meets the two-month time limit, and schedule the yearly notice to employees about their right.
• Count the average number of employees for 2026. With 150 or more, collect the pay data for the report due by 7 June 2027; with 100 to 149, plan for 7 June 2031; that duty depends on the average number of employees in 2030.
• Obtain from temporary employment agencies the pay data for agency workers.
• Keep the documents that show how each pay decision follows from the criteria. In a dispute the employer will have to prove it.
• Handle the pay data in line with the GDPR and limit access to those who need it.

How L+A works with employers

L+A acts for employers. We review pay structures and the criteria behind them against article 37 of the Labour Code, and adapt recruitment documents, employment contracts, confidentiality terms and work rules to the new rules. We prepare the internal procedure for employees' information requests, advise on the pay gap report and on the joint pay assessment together with the payroll provider or accountant the client has chosen, who produces the figures, and represent the employer before the Labour Inspectorate, the Ombudsman and the Greek courts.

The work is led by senior lawyers of the firm, which has its seat in Piraeus and a presence in Alimos, Athens, in English and Greek, by email. This page is general information, not legal advice. It does not deal with the public sector, payroll calculations, the statistical method of the pay gap figures, or collective agreements in particular sectors. Ministerial decisions provided for by the law, on fines and on the reporting platform, may add detail. Reviewed on 11 November 2026.

Sources

Statutes and official sources for the facts on this page:

• Directive (EU) 2023/970 of the European Parliament and of the Council of 10 May 2023 (OJ L 132, 17.5.2023, p. 21; CELEX 32023L0970): art. 5 (pay transparency prior to employment), art. 6 (pay setting and pay progression), art. 7 (right to information), art. 9 (reporting on the pay gap), art. 10 (joint pay assessment), art. 12 (data protection), art. 16 (compensation), art. 18 (shift of burden of proof), art. 21 (limitation periods), art. 23 (penalties), art. 25 (victimisation), art. 34 (transposition by 7 June 2026).
• Law 5316/2026 (Gazette Α' 105/6.7.2026), Part Α (arts 1 to 31, transposition of Directive (EU) 2023/970): arts 4 to 5 (scope and definitions), arts 8 to 13 (pay transparency duties), arts 15 to 18 and 20 (remedies), arts 21 to 23 (Ombudsman), art. 27 (disputes before the Labour Inspectorate), art. 30 (transitional provisions), art. 31 (enabling provisions) and art. 48 (entry into force: 6 July 2026; arts 8 to 20 and 27 from 1 November 2026).
• Labour Code (Κώδικας Εργατικού Δικαίου), Presidential Decree 62/2025 (Gazette Α' 121/11.7.2025), as amended by Law 5316/2026: art. 35 (definitions; codifies art. 2 of Law 3896/2010), art. 37 (equal pay and pay transparency; art. 4 of Law 3896/2010), art. 41 (access to employment and pay transparency; art. 11 of Law 3896/2010), art. 44 (protection against retaliation; art. 14 of Law 3896/2010), art. 47 (scope; art. 17 of Law 3896/2010), art. 52 (legal protection), art. 53 (civil and administrative sanctions, right to compensation), art. 54 (burden of proof), art. 55 (Ombudsman as equality and monitoring body), arts 56Α to 56Δ (right to information, pay gap reporting, joint pay assessment, data protection), art. 57Α (enabling provisions), art. 570Α (pay disputes before the Labour Inspectorate), art. 572 par. 1 (administrative sanctions), art. 573 par. 3Α (compliance orders) and art. 576Α.
• Law 3094/2003 (Gazette Α' 10), art. 3 par. 7 and art. 10Α, as added by arts 23 and 31 of Law 5316/2026 (Ombudsman: collection and publication of pay gap data).
• Law 3896/2010 (Gazette Α' 207), equal treatment of men and women in employment, codified in arts 34 to 57 of the Labour Code; Law 4443/2016 (equal treatment on other grounds), codified in arts 16 to 33 of the Code.
• Government Gazette, series Α', issues 106 to 185 of 2026 (to 9 November 2026), searched on 11 November 2026 for later amendments of the above articles: none found.